Five Ways to Ensure Response Plans Really Work

EPA and OSHA require facilities to have a variety of written plans to address workplace hazards and emergency response and to outline the available resources and responses to handle those situations. Many of these regulations require annual or "regular" updates, but too often, only the date changes on the plan and it becomes less of a resource over time.

As facilities tighten budgets and safety and environmental compliance officers take on additional duties, the time spent to thoroughly and regularly review response plans should not be sacrificed or lessened. Reviewing response plans is just as important as other vital safety checks that are done on a more frequent basis.

A response plan that is covered with a layer of dust can be just as much of a hazard as a broken machine guard or a non-functioning emergency shower. None will properly guard against the hazard it is intended to correct. Unfortunately, and especially when response plans aren't reviewed frequently, the task often takes a bit more time than other safety audits –- but keeping the task forever on the bottom of a "to-do" list is the same as allowing an unsafe practice to go unchecked in the workplace.

An emergency is not the time to find out that the plant manager listed as the key contact tasked with evacuating the entire processing area retired three years ago and no one seems to know the name of the new one, or that floor plans have changed and the exit routes are no longer viable. Use the following five ideas to help ensure that facility response plans are up to date and effective.

1. Take a field trip. In a year's time, a lot can change within a facility. Offices and entire departments can move. Floor plans change. People retire or move to different positions. Walking through the entire facility does take time, but it is one of the most effective ways to make sure that processes, chemicals, and people haven't changed since the plan was last reviewed.

While visiting each area, review the plan's elements with people in the area to make sure they're still logical, especially if processes or personnel have changed. There may be a safer way to do something that wasn’t known or available a year ago. This is also a good time to verify contact information (such as phone extensions, cellular phone numbers, pager numbers, etc.) is still correct.

Reviewing the minutes from safety committee meetings or after-action reports from emergency drills may help to uncover improvements or changes that need to be made.

2. Go outside the box. Even if the field trip from step one results in no changes or updates to the plan -– unlikely, but possible -– having outside experts review facility response plans can help to identify subtle changes or enhancements that will improve safety during a response. This doesn't mean hiring a high-priced consultant. Often, free resources are available locally.

Most Local Emergency Planning Committees (LEPCs) or Emergency Management Agency (EMA) offices are eager to help facilities review their emergency response plans. Because they are familiar with response planning, they can help identify areas for improvement and can be used as a sounding board for new plan ideas that the facility may want to implement.

Local responders, such as firefighters, the hazmat team, and other emergency services, also can be helpful in auditing or reviewing response plans. Because they are often called upon to assist in an emergency, allowing them to become familiar with the facility and the response plan can be extremely valuable during an actual response because they will be able to provide aid more quickly than if they arrive with no prior knowledge.

3. Pick up the phone. Outdated contact information is a very common problem with response plans. It's hard enough to keep track of internal personnel changes, but external changes can cause significant problems, as well.

Many facilities maintain a list of suppliers and contractors for response materials such as backhoes or other response equipment. For facilities that donj't routinely need these materials and don’t check contact lists in their response plans, it can be years before it is realized that the rental company specified in the plan is no longer in business.

<'>Local, county, state, and federal contacts also change frequently. The time to find out there's a new county EMA director is not when he's at the front gate during an emergency.

4. Take a page from the plan. Select five or 10 employees who are not safety committee or response team members and give them a copy of the response plan, or at least the section or sections that would apply to them -– such as the evacuation plan. Ask them to follow the plan's instructions as written and to make notes about how well they were able to follow the plan, whether the plan worked, or where and when it didn't work.
As with having the LEPC or EMA review response plans, having a fresh set of eyes can help to uncover processes or planning elements that may be taken for granted.

5. Conduct regular training and drills. An initial training when someone is hired isn't enough. Response plans need to be communicated and rehearsed regularly, and each employee should know his or her duty when it comes to response. Some regulations are specific about how often trainings or refreshers need to occur. For example, spill responders trained to the technician level under OSHA's Hazardous Waste Operations and Emergency Response (HAZWOPER) standard need to have an annual refresher to maintain their certification.
Does everyone know what to do when there is an emergency? Should they turn off a machine before they evacuate? Should they use a fire extinguisher or pull an alarm? Where do they go when they evacuate? Whom do they report to after they have safely evacuated? Response plans should clearly address these questions.

Even if not specifically required by a regulation, conducting annual training and drills is a proven way to help ascertain whether or not a response plan will work in an actual emergency. Inviting local responders to observe drills can be a valuable asset and can help facilitate "hot washes" or "after-action reviews" at the end of drills to identify both the things that went well and the things that may need to be improved in a response plan.

Between drills, use facility intranet sites, signs, posters, and wallet cards to help reinforce proper response actions. Regularly reviewing plans and updating them takes time, but is an essential element in safety planning that can help save lives and ensure safety for responders.

This article originally appeared in the June 2012 issue of Occupational Health & Safety.

About the Author

Karen D. Hamel is a technical specialist for New Pig Corp. She has more than 20 years of experience helping environmental, health, and safety professionals find solutions to meet EPA, OSHA, and DOT regulations. She is a hazmat technician, serves on the Blair County, PA LEPC, is a CERT trainer, and has completed a variety of hazmat response and NIMS courses, including Planning Section Chief. She can be reached at 1-800-HOT-HOGS(r) (468-4647) or by email to karenh@newpig.com.